This Thursday, May 5, I am excited to share Lessons Learned from 2022 Office of Inspector General (OIG) Enforcement, Corporate Integrity Agreements (CIAs) and Integrity Agreements (IAs). In this installment of Harris Beach’s Health Care Fraud & Abuse Webinar Series, I will summarize OIG’s 2022 published enforcement actions that serve to illustrate what OIG and various states’ Medicaid Fraud Control Units consider to be fraud, as well as violations of the Federal and state anti-kickback statutes and the Stark Law.
Some recent examples of enforcement activity include billing patients for out-of-pocket costs that exceed services provided and services not covered by a patient consent; problems when using patient recruiters and marketers; using Medicaid beneficiaries’ and providers’ information to bill for services never rendered or requested; telemedicine billing fraud; and requiring potentially unnecessary testing (such as genetic or psychological testing) before being seen by a physician.
The 2022 Corporate Integrity Agreements and Integrity Agreements provide insight into what OIG considers is necessary in compliance and ethics programs for providers who have engaged in an excludable offense. Some recent CIAs require the Compliance Officer for a large physician office practice to monitor all orders for testing to confirm that the tests were necessary; and prepare monthly and quarterly testing reviews after consultation with the Medical Director. Other CIAs mandate a Quality Review Organization for a hospital to conduct specific quality reviews. The CIAs executed in the first four months of 2022 have impacted providers that are physician practices, a hospital system, and pharmaceutical companies/distributors.
The webinar will start at 9:00 AM and run until 10:30 AM. Questions will be taken during the program.
Register here for our Fraud & Abuse Webinar.